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2018 (1) TMI 1155 - ITAT HYDERABADALP determination - TPA - comparable selection - Held that:- We find that the issue before the ITAT was the average margin of the comparables and it had been confirmed at 29.51%. The Tribunal has, thereafter, directed only for re-computing the ALP after allowing the marketing expenses. Therefore, there was no discretion left to the authorities below for re-computing the ALP. The remand was only for the calculation of the ALP and not for verification of the expenses which have already been accepted and quantified by the TPO in the earlier proceedings. Therefore, the AO/TPO are directed to calculate the ALP exactly in the way directed by the ITAT. - Decided in favour of assessee
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